Report to Congressional Requesters

United States General Accounting Office

GAO

November 2001 JUSTICE

DISCRETIONARY

GRANTS

Byrne Program and

Violence Against

Women Office Grant

Monitoring Should Be

Better Documented

GAO-02-25
Page i GAO-02-25 Justice Discretionary Grants

Letter 1

Results in Brief 2

Background 5

Scope and Methodology 7

Discretionary Grant Monitoring and Requirements 9

BJA and VAWO Grant Files Did Not Always Contain Adequate

Documentation That Monitoring Occurred 11

BJA and VAWO Are Not Positioned to Systematically Determine

Staff Compliance With Monitoring Requirements and Assess

Overall Performance 21

OJP’s Efforts to Resolve Continuing Grant Monitoring Problems 23

Conclusions 27

Recommendations for Executive Action 28

Agency Comments and Our Evaluation 28

Appendix I Size and Growth of OJP, BJA, and VAWO Budgets and

BJA and VAWO Discretionary Grant Programs 31

Budget Increases at OJP, BJA, and VAWO in the 1990s 31

Discretionary Grant Award Increases at BJA and VAWO in the

1990s 32

Appendix II Stages of the Discretionary Grant Process 36

Appendix III Comments From the Department of Justice 39

GAO Comments 49

Appendix IV GAO Contacts and Staff Acknowledgments 51

GAO Contacts 51

Staff Acknowledgments 51

Tables

Table 1: Estimated Timeliness of Progress Report Submissions 16

Table 2. Estimated Timeliness of Financial Report Submissions 17

Contents
Page ii GAO-02-25 Justice Discretionary Grants

Figures

Figure 1: Overall OJP, BJA, and VAWO Yearly Budget Resources 6

Figure 2: Overall OJP and BJA and VAWO Yearly Budget Resources 32

Figure 3: Overall Yearly BJA Discretionary Awards 33

Figure 4: Dollar Amount of Overall BJA Discretionary Awards 34

Figure 5: Number of Yearly VAWO Discretionary Awards 35

Figure 6: Dollar Amount of VAWO Discretionary Awards 35

Figure 7: Life of a Discretionary Grant 36

Figure 8: Supplemental Award Process and Time Frame 38

Abbreviations

BJA Bureau of Justice Assistance

DOJ Department of Justice

GMS Grant Management System

GPRA Government Performance and Results Act of 1993

OJP Office of Justice Programs

VAWO Violence Against Women Office
Page 1 GAO-02-25 Justice Discretionary Grants

November 28, 2001

The Honorable Charles E. Grassley

Ranking Minority Member

The Honorable Jeff Sessions, Member

Subcommittee on Youth Violence

Committee on the Judiciary

United States Senate

This report responds to your request that we review selected aspects of

the U.S. Department of Justice’s (DOJ) Office of Justice Program’s (OJP)

grant monitoring and evaluation efforts. Specifically, this report discusses

the program monitoring of discretionary grants awarded by the Bureau of

Justice Assistance’s (BJA) Byrne Program1

 and the Violence Against

Women Office (VAWO) within OJP. Between fiscal years 1997 and 2000,

Byrne and VAWO discretionary grant awards grew, in constant 2000

dollars, about 85 percent—from about $105 million to approximately $194

million. These funds were awarded directly to various organizations, such

as state and local governments, either on a competitive basis or pursuant

to legislation allocating funds through congressional earmarks. BJA and

VAWO, together with OJP’s Office of the Comptroller, were responsible for

monitoring these grants to ensure that they were being implemented as

intended, responsive to grant goals and objectives, and compliant with

statutory regulations and other policy guidelines.

To address your request, we reviewed and are reporting on (1) OJP’s

discretionary grant monitoring process and requirements, (2) the extent to

which BJA and VAWO documented their monitoring activities for

discretionary grants, (3) what BJA and VAWO do to determine compliance

with OJP’s grant monitoring guidelines, and (4) OJP’s efforts to identify

and address grant monitoring problems.2

 To meet our objectives, we

interviewed agency officials and grant managers and supervisors in

Washington, D.C.; reviewed OJP, BJA, and VAWO policies, procedures,

 1

The Edward Byrne Memorial State and Local Law Enforcement Assistance Program

Discretionary Grants Program is the largest single discretionary grant program within BJA.

2

In October 2001, we issued a similar report on the documentation of discretionary grant

monitoring by OJP’s Office of Juvenile Justice and Delinquency Prevention, entitled

Juvenile Justice: Better Documentation of Discretionary Grant Monitoring Is Needed

(GAO-02-65, Oct. 10, 2001).

United States General Accounting Office

Washington, DC 20548
Page 2 GAO-02-25 Justice Discretionary Grants

and practices for and OJP reports on administering and monitoring grants;

analyzed data from a representative sample of 46 of 110 Byrne and 84 of

635 VAWO grant files active during 1999 and/or 2000; and analyzed OJP,

BJA, and VAWO budget data on OJP grant programs from fiscal years 1990

through 2000. As agreed with your staff, we focused on monitoring

activities associated with the Byrne and VAWO discretionary grant

programs that supported a program or theme, rather than those that

supported training and technical assistance.

Our analysis did not address how well BJA and VAWO monitored their

grantees. For example, we reviewed documentation to determine whether

BJA and VAWO made the site visits they said they would conduct, but it

was not feasible to review how well they conducted the site visits. Further,

we did not examine OJP’s efforts to conduct financial monitoring of Byrne

and VAWO discretionary grants through the Office of Comptroller. For

purposes of this report, a grant consists of an initial award and any

subsequent supplemental awards. Thus, when we reviewed a grant file, we

reviewed all award files within each grant.

OJP has monitoring and documentation requirements for its discretionary

grants. The monitoring requirements include the development of

monitoring plans that articulate who will conduct monitoring, the manner

in which it will be done, and when and what type of monitoring activities

are planned. Grant managers are to maintain documentation in grant files

on their monitoring activities, using such techniques as written reports of

on-site reviews and telephone interview write-ups. Grant files are also to

include program and financial progress reports submitted by grantees to

OJP at defined intervals, and grant managers are to notify grantees when

reports are delinquent. In addition, when grants are closed, grant files are

supposed to contain key documents, including all financial and progress

reports and the final accounting of federal funds.

Our review of a representative sample of 46 Byrne and 84 VAWO

discretionary grants showed that they did not always contain the required

monitoring plans: an estimated 29 percent of Byrne and 11 percent of

VAWO award files did not contain monitoring plans. In addition, for

awards covering the most recent 12-month period of grant activity, grant

managers were not consistently documenting their monitoring activities

according to the monitoring plans they developed. For example, 25 of 46

Byrne and 53 of 84 VAWO files had plans with specific criteria for site

visits. Of these 25 Byrne files, 21 did not contain documentation to show

whether all the planned site visits occurred. For the VAWO files, we

Results in Brief
Page 3 GAO-02-25 Justice Discretionary Grants

estimate that 90 percent of all files did not contain documentation that all

the planned site visits occurred. Our review of grant files also showed the

following:

• A substantial number of Byrne and VAWO files did not contain progress

and financial reports sufficient to cover the entire grant period. For

example, an estimated 70 percent of Byrne and 66 percent of VAWO files

did not have progress reports to cover the complete grant period, and an

estimated 41 percent of Byrne and 36 percent of VAWO grant files did not

contain financial reports covering the full grant period. In addition, seven

of the files we reviewed—three Byrne and four VAWO—did not contain

any of the required grantee progress reports.

• Progress and financial reports were often submitted late by grantees. An

estimated 68 percent of Byrne and 85 percent of VAWO progress reports

were late, and 53 percent of Byrne and 54 percent of VAWO financial

reports were late.

• The Byrne and VAWO files we reviewed did not always contain the

required closeout documents. There were not enough closed Byrne or

VAWO grants to ensure that our assessment was representative of all grant

closeouts. However, our limited review showed that of the 19 closed Byrne

grants we reviewed, 15 did not contain documentation of the required

precloseout contact with the grantee, 10 did not contain the final progress

report, and 7 did not contain the final financial report. Of the 3 closed

VAWO grants we reviewed, 3 did not contain documentation of the

required precloseout contact with the grantee, 2 did not contain the final

progress report, and 1 did not contain the final financial report.

BJA and VAWO are not positioned to systematically oversee grant

managers’ compliance with monitoring requirements because

documentation is not readily available on monitoring activities. Both BJA

and VAWO rely on staff meetings and discussions with staff to identify

grant problems or monitoring issues, and neither have management

information systems that enable them to compile and analyze data about

most monitoring activities. The lack of systematic data for monitoring

grant manager compliance, combined with a failure to document

monitoring activities, could impede BJA and VAWO’s ability to measure

their performance consistent with the Government Performance and

Results Act of 1993 (GPRA).3

 For example, DOJ’s Fiscal Year 2000

Performance Report and 2002 Performance Plan list three VAWO program

 3

P.L. 103-62.
Page 4 GAO-02-25 Justice Discretionary Grants

targets and performance measures for which needed performance data are

to be derived from grantee progress reports, on-site monitoring, and

VAWO program office files—all validated and verified through a review of

monitoring information. Although the performance report and plan state

that the goals and measures have no known limitations, questions arise as

to whether inconsistent documentation and the lack of systematic data

could hinder VAWO’s ability to measure whether it is achieving its goals.

Problems with OJP grant monitoring are not new. Over the last few years,

we and others, including OJP, have identified various grant monitoring

problems among OJP’s bureaus and offices. For example, since 1996, we

have testified and issued reports that discuss inconsistent documentation

of discretionary grant monitoring activities in OJP’s Office of Juvenile

Justice and Delinquency Prevention and Executive Office for Weed and

Seed. In addition, reports by or for OJP have found similar problems

among OJP’s bureaus and offices. The DOJ Office of Inspector General has

declared OJP grant management a major management challenge. OJP has

begun to work with its bureaus and offices, like BJA and VAWO, to

address these problems, but it is too early to tell whether OJP’s efforts will

effectively resolve many of the issues we and others, including OJP itself,

have identified. For example, although OJP has issued new guidance on

grant monitoring and is soliciting the opinions of grant managers regarding

the usefulness of its new guidance, OJP has not considered what it plans

to do to test compliance and ensure that grant managers are documenting

their activities.

We are making recommendations regarding (1) BJA and VAWO’s need to

improve their documentation of discretionary grant monitoring and (2)

OJP’s need to establish an approach to compile, maintain, and

systematically review documentation of monitoring activities.

In commenting on a draft of this report, OJP’s Assistant Attorney General

said that overall, the report provides useful information by highlighting

monitoring activities that need improvement (see appendix III). She noted

that BJA and VAWO had already taken steps to address our

recommendations regarding their monitoring activities, but she was silent

about what OJP planned to do to address our recommendations regarding

OJP’s need to establish an approach to compile, maintain, and

systematically review documentation of monitoring activities. We

acknowledge that BJA and VAWO appear to be taking steps in the right

direction. However, until their actions become operational, BJA and

VAWO will not be able to determine why the problems we identified

occurred so that they can take corrective action. In addition, although
Page 5 GAO-02-25 Justice Discretionary Grants

these steps might help BJA and VAWO better understand and act upon the

problems we identified, they appear to be specific to those organizations.

Thus, it is unclear whether and to what extent these actions can be applied

OJP-wide so that OJP can begin to address the long-standing monitoring

problems we and others, including OJP, have identified.

OJP, the grant-making arm of DOJ, provides grants to various

organizations, including state and local governments, universities, and

private foundations, that are intended to develop the nation’s capacity to

prevent and control crime, administer justice, and assist crime victims.

OJP’s Assistant Attorney General is responsible for overall management

and oversight of OJP through setting policy and for ensuring that OJP

policies and programs reflect the priorities of the President, the Attorney

General, and the Congress. The Assistant Attorney General promotes

coordination among the various bureaus and offices within OJP, including

BJA, one of the five bureaus within OJP, and VAWO, one of OJP’s seven

program offices.4

 In fulfilling its mission, BJA provides grants for sitebased programs and for training and technical assistance to combat

violent and drug-related crime and help improve the criminal justice

system. VAWO administers grants to help prevent, detect, and stop

violence against women, including domestic violence, sexual assault, and

stalking.

Since 1996, OJP’s budget has increased substantially, following the

passage of the Violent Crime Control and Law Enforcement Act of 1994.5

Figure 1 shows changes to OJP’s budget from fiscal year 1990 through

fiscal year 2000 and compares those changes in relation to BJA’s budget

over the same period and VAWO’s budget since its inception in 1995.

 4

OJP’s five bureaus are Bureau of Justice Assistance, Bureau of Justice Statistics, National

Institute of Justice, Office of Juvenile Justice and Delinquency Prevention, and Office for

Victims of Crime. OJP’s seven program offices are American Indian & Alaska Native Affairs

Desk, Violence Against Women Office, Executive Office for Weed and Seed, Corrections

Program Office, Drug Courts Program Office, Office for State and Local Domestic

Preparedness Support, and Office of the Police Corps and Law Enforcement Education.

5

P.L. 103-322.

Background
Page 6 GAO-02-25 Justice Discretionary Grants

Figure 1: Overall OJP, BJA, and VAWO Yearly Budget Resources

Note 1: According to OJP budget officials, yearly figures include all funds appropriated to OJP,

transfers from other agencies, and receipts from the Crime Victim Fund, which is derived not from tax

dollars, but from fines and penalties paid by federal criminal offenders. However, the yearly figures do

not include grants awarded and administered by OJP bureaus and offices for other federal agencies

(including other DOJ agencies) under reimbursable agreements. Also, the yearly amounts do not

include direct appropriations for OJP management and administration. The large funding increase for

fiscal year 1996 resulted from the Omnibus Consolidated Recissions and Appropriations Act of 1996,

which appropriated funds authorized by the Violent Crime Control and Law Enforcement Act of 1994.

Note 2: The budget amounts for each fiscal year are adjusted to constant fiscal year 2000 dollars.

Source: OJP Office of Budget and Management Services.

One of BJA’s major grant programs is the Edward Byrne Memorial State

and Local Law Enforcement Assistance Program.6

 Under the Byrne

Discretionary Grants Program, BJA provides federal financial assistance to

grantees for educational and training programs for criminal justice

personnel; technical assistance to state and local units of government; and

projects that are replicable in more than one jurisdiction nationwide. In

fiscal year 2000, BJA awarded 99 Byrne discretionary grants worth about

$69 million.

 6

Local law enforcement programs established by the Anti-Drug Abuse Act of 1986 (P.L. 99-

570) were amended and renamed the Edward Byrne Memorial State and Local Law

Enforcement Assistance Program by the Anti-Drug Abuse Act of 1988 (P.L. 100-690). The

Byrne grant program is codified at 42 U.S.C. 3750-3766b. The Byrne program is one of

approximately 20 programs administered by BJA.
Page 7 GAO-02-25 Justice Discretionary Grants

VAWO was created in 1995 to carry out certain programs created under

the Violence Against Women Act of 1994.7

 The Victims of Trafficking and

Violence Prevention Act of 20008

 reauthorized most of the exisiting VAWO

programs and added new programs as well. VAWO’s mission is to lead the

national effort to end violence against women, including domestic

violence, sexual assault, and stalking. VAWO programs seek to improve

criminal justice system responses to these crimes by providing support for

law enforcement, prosecution, courts, and victim advocacy programs

across the country. In addition, programs are to enhance direct services

for victims, including victim advocacy, emergency shelter, and legal

services. VAWO also addresses violence against women issues

internationally, including working to prevent trafficking in persons. In

fiscal year 2000, VAWO awarded 425 discretionary grants worth about

$125 million.

Appendix I discusses the growth in OJP, BJA, and VAWO budgets and

provides information on the number and amount of BJA and VAWO

discretionary grants awarded from fiscal year 1990 to fiscal year 2000.

To meet our objectives, we conducted our work at OJP, BJA, and VAWO

headquarters in Washington, D.C. We reviewed applicable laws and

regulations and OJP, BJA, and VAWO policies and procedures for

awarding and managing grants, and we interviewed responsible OJP, BJA,

and VAWO officials, including grant managers. As agreed with your

offices, we focused on monitoring activities associated with the Byrne and

VAWO discretionary grant programs. In particular, we focused on grant

monitoring for grants that were active during fiscal years 1999 and 2000

and supported a program or theme, rather than technical assistance or

training efforts.

To address our first objective, concerning OJP’s process and requirements

for discretionary grant monitoring, we reviewed applicable laws and

regulations and OJP policies and procedures for grant administration and

grant monitoring. We also interviewed OJP, Comptroller, BJA, and VAWO

staff. We obtained information about the Comptroller’s Control Desk,

which maintains the official grant files and is responsible for receiving,

 7

Title IV of the Crime Act (P.L. 103-322).

8

P.L. 106-386.

Scope and

Methodology
Page 8 GAO-02-25 Justice Discretionary Grants

distributing, and tracking grant documents, including financial and

progress reports.

To address our second objective regarding the extent to which BJA and

VAWO documented their monitoring activities for discretionary grants, we

reviewed representative samples of official grant files and grant manager

files using a data collection instrument to record whether evidence of the

required monitoring activity—progress reports, financial reports, and

other required documents—were included in the files. For each grant, we

also reviewed the most recent award covering 12 months to examine the

documentation of specific monitoring requirements and activities, such as

telephone calls and site visits.9

 Specifically, we reviewed a random sample

of 46 of 110 Byrne and 84 of 635 VAWO discretionary grants that had a

program theme and were active throughout fiscal year 1999 or 2000. The

results of the samples are representative of the populations from which

they were drawn. We express our confidence in the precision of our

sample results as a 95-percent confidence interval. Unless otherwise

noted, all confidence intervals are less than or equal to plus or minus 10

percentage points.

In regard to grantee financial and progress reports, we reviewed all

available reports for the BJA and VAWO discretionary grants included in

our sample from the initiation of the grant through December 31, 2000. We

determined timeliness using dates recorded on reports compared with the

specified intervals when they were supposed to be received. Also, to

determine whether BJA and VAWO closeout procedures were

implemented in accordance with OJP policy, we reviewed those grant files

in our sample when the grant end date was between September 30, 1999,

and August 31, 2000. For our review, we focused on required closeout

documentation, such as precloseout contacts, closeout checklists, and

final financial and progress reports.

To address our third objective, regarding how BJA and VAWO determine

compliance with OJP monitoring requirements, we requested information

on any existing oversight and review processes relating to grant

 9

A grant consists of an initial award, any subsequent supplemental awards and grant

adjustment notices. Grant adjustment notices are completed for changes to the grant (e.g.,

project period extensions or budget modifications). Once reviewed and certified, the grant

adjustment notice communicates approval of such changes by the appropriate OJP office.

Therefore, when we reviewed a grant file, we reviewed all award files within each grant, as

well as all relevant grant adjustment notices.
Page 9 GAO-02-25 Justice Discretionary Grants

monitoring at BJA and VAWO and gathered and reviewed documentation

that BJA and VAWO officials provided concerning their oversight

processes. We also met with BJA and VAWO officials to obtain information

on any new initiatives they had to address the oversight and management

of their grants.

To meet our fourth objective, on OJP’s efforts to identify and address

grant management problems, we met with OJP officials to discuss their

efforts, and we reviewed reports and documents they had prepared about

the new Grant Management System (GMS), revisions to the OJP Handbook

and associated decision documents, and other initiatives. In addition, we

reviewed the DOJ Fiscal Year 2000 Performance Report and Fiscal Year

2002 Performance Plan and information on grant management developed

by the DOJ’s Office of the Inspector General.

Finally, to obtain information on the size and growth of BJA and VAWO

grant programs within the context of OJP, we obtained and analyzed

budget and resource data from OJP on grant funds and programs from

fiscal years 1990 through 2000.

We conducted our work between October 2000 and October 2001 in

accordance with generally accepted government auditing standards.

We requested comments on a draft of this report from DOJ on October 24,

2001. Its comments are discussed near the end of this letter and are

reprinted as appendix III. DOJ also provided technical comments that

were incorporated in the report.

After BJA and VAWO award discretionary grants, OJP policies require

them, in coordination with Office of the Comptroller, to monitor grants

and related activities and document the monitoring results. Monitoring is

done to ensure

• compliance with relevant statutes, regulations, policies, and guidelines;

• responsible oversight of awarded funds;

• implementation of approved programs, goals, objectives, tasks, products,

time lines, and schedules;

• identification of issues and problems that may impede grant

implementation; and

• implementation of adjustments by the grantee as approved by BJA or

VAWO.

Discretionary Grant

Monitoring and

Requirements
Page 10 GAO-02-25 Justice Discretionary Grants

The OJP Handbook is the basic reference for OJP policies and procedures

for the administration of OJP grants, including discretionary grant

monitoring.10 According to the Handbook, each grant manager is to

prepare a monitoring plan as part of a grant manager’s memorandum

recommending initial or continuation funding. The level of monitoring is to

be based on the stated monitoring plan in the grant manager’s

memorandum. The plan is to contain information on who will conduct the

monitoring, how it will be done, and when and what type of monitoring

activities are planned. Monitoring information is to be collected using such

techniques as on-site visits, telephone calls, and desk reviews, which are

reviews to ensure that the grant files are complete and the grantee is in

compliance with the program guidelines.

In addition, grant managers are to review grantee program and financial

progress reports. According to OJP’s Handbook, grantees are required to

submit periodic progress reports that summarize project activities to aid

program and grant managers in carrying out their responsibilities for

grant-supported activities.11 Likewise, grantees are required to submit

periodic financial status reports to update OJP on how grant funds are

being spent. In addition, OJP requires that grant managers close out the

grant when the project period ends to ensure that the agency has received

all required financial, programmatic, and audit reports and that all federal

funds have been accounted for.

OJP bureaus and program offices, such as BJA and VAWO, are to carry out

the program (nonfiscal) monitoring aspects of the grants they award.

During fiscal year 2000, BJA had approximately 20 program managers

responsible for the monitoring activities for most nonformula BJA grants.

Generally, each BJA program manager had responsibility for monitoring

25 to 40 discretionary grants, including those under the Byrne program.

VAWO had 13 program managers, each of whom had responsibility for the

program monitoring aspects for about 60 VAWO grants, including VAWO

discretionary grants.

 10OJP, OJP Handbook: Policies and Procedures for the Administration of OJP Grants

(Washington, D.C.: Feb. 1992). In January 2001, OJP released Grant Management Policies

and Procedures Manual to update OJP’s policies and procedures for grant management

activities. This manual supersedes and cancels the 1992 Handbook. The revised policies

and procedures were not applicable to the grant periods covered by our review.

11In 1996, OJP changed its procedures to require grantees to submit progress reports

semiannually. Before then, grantees had to submit progress reports quarterly.
Page 11 GAO-02-25 Justice Discretionary Grants

The Office of the Comptroller has primary responsibility for monitoring

the fiscal aspects of all OJP-awarded grants, including those awarded by

BJA and VAWO. To assess grantee financial records, the Comptroller’s

Monitoring Division is to perform risk-based, on-site financial reviews for

a sample of grantee organizations to monitor administrative and financial

capability.12 The Monitoring Division is to review various program and

financial documents contained in the official grant files to ensure that they

are complete and the documents are properly executed. For discretionary

grants, the Monitoring Division conducted 36 desk reviews for Byrne and

38 for VAWO discretionary grants in fiscal year 1999 and 6 desk reviews

for Byrne and 16 for VAWO discretionary grants in fiscal year 2000. In

addition, the Control Desk is to maintain the official grant files and is

responsible for tracking the receipt of all grantee documents. The Control

Desk is to receive grantee progress and financial reports, log the date of

receipt into a tracking system, file the original in the official grant file, and

forward a copy to the cognizant program office. The Control Desk also is

to generate a monthly report on delinquent progress and financial reports,

which is distributed to responsible officials within bureaus and program

offices. BJA and VAWO grant managers are responsible for ensuring that

grantees submit timely progress and financial reports and are to contact

the grantee if reports are delinquent.

Appendix II discusses grant monitoring within the context of the grant

award process throughout the life of a grant.

OJP requires that grant managers document their monitoring of the grants.

This documentation is to include both the grant manager’s written plan for

monitoring the project and grantee progress and financial reports. In

addition, OJP requires certain documentation at the time of grant

closeouts from both the grantee and the grant manager. Byrne and VAWO

grant files did not always contain monitoring plans, and grant managers

were not consistently documenting their monitoring activities, according

to the monitoring plans that we reviewed. In fact, for those award files

representing the most recent 12-month period of activity for each grant,

few contained records to show that such activities as telephone contacts

and site visits occurred. Furthermore, the progress and financial reports

did not always cover the entire period covered by the award, a few grants

 12The Comptroller’s Monitoring Division applies risk-based criteria to a universe of grants

to develop a sample for each fiscal year’s monitoring plan based on the dollar amount of

the grant, new grantees, new grant programs, and programs with known problems.

BJA and VAWO Grant

Files Did Not Always

Contain Adequate

Documentation That

Monitoring Occurred
Page 12 GAO-02-25 Justice Discretionary Grants

were missing all progress reports, and progress and financial reports were

often late. For those closed grants that we reviewed, key documents,

which are to ensure a final accounting of federal funds and show whether

the grantee met the programmatic goals of the grant, were sometimes

missing.

Our review of grant files showed that monitoring plans were not always in

the files. Each grant may contain one or more individual grant awards,13

and for each award, OJP requires that grant managers prepare a

monitoring plan containing information on, among other things, who will

conduct the monitoring, how it will be done, and when and what type of

monitoring activities and reports are planned. Our review of

documentation on the awards in 46 Byrne grant files and 84 VAWO grant

files showed that an estimated 29 percent of the Byrne awards and about

11 percent of the VAWO awards did not contain a grant manager’s

monitoring plan.14

We also compared the planned monitoring activities in the monitoring

plans for the most recent 12-month period of grant activity for each of the

46 Byrne and 84 VAWO grant files to actual monitoring documentation. Of

those files that contained a monitoring plan, some had specific plans for

monitoring, while others did not. When the file contained a plan that

outlined the type of monitoring and its frequency, our review showed that

the documentation in the files was inadequate to demonstrate whether or

not BJA and VAWO grant managers were consistently following the

monitoring plans. For Byrne files, there were not enough monitoring plans

with specific planned activities to ensure that our assessment was

representative of all the awards. However, our limited comparisons of

planned to actual documentation regarding phone contacts, site visits, and

desk reviews revealed the following:

• Phone Contacts. 13 of 46 Byrne files contained monitoring plans that

specified the planned number and frequency (e.g., monthly or quarterly) of

telephone contacts to be made. Of those 13 files, none contained

documentation to show that all of the planned number of telephone

contacts occurred. Furthermore, 4 of the 13 files had documentation that

showed that some, but not all, of the planned telephone contacts had been

 13For further discussion of the life of a grant and subsequent awards, see appendix II.

14The 46 Byrne grants contained 76 awards, and the 84 VAWO grants contained 152 awards.

Missing Monitoring Plans

and Inadequately

Documented Monitoring

Activities
Page 13 GAO-02-25 Justice Discretionary Grants

made, while the remaining 9 files contained no documentation that any

telephone contacts occurred.

• Site Visits. 25 of 46 Byrne files contained monitoring plans that specified

the number of grantee site visits to be conducted, but only 4 of 25 files

contained documentation that showed that the planned number of site

visits occurred. Only 1 of the 25 files had documentation that some, but

not all, of the site visits had been made, and the remaining 20 of the 25 files

contained no documentation that any site visits occurred.

• Desk Reviews. 15 of 46 Byrne files contained monitoring plans that

specified the frequency of desk reviews to be conducted. However, none

of the files showed evidence that any desk reviews were conducted.

Our assessment of the VAWO files provided enough cases to develop a

representative sample of all available VAWO monitoring plans.

Specifically, our review of planned to actual monitoring activities—phone

contacts, site visits, and desk reviews—showed the following:

• Phone Contacts. 59 of 84 VAWO files contained monitoring plans that

specified the planned number and frequency (e.g., monthly or quarterly) of

telephone contacts to be made. However, none contained documentation

to show that the planned number of telephone contacts occurred.

Furthermore, we estimate that 56 percent of VAWO files had

documentation that some, but not all, of the planned telephone contacts

had been made, and 44 percent of VAWO files15 with monitoring plans

containing criteria for a specific number of telephone contacts had no

documentation that any telephone contacts occurred.

 15The estimated range is between 31 and 58 percent.
Page 14 GAO-02-25 Justice Discretionary Grants

• Site Visits. 53 of 84 VAWO files contained monitoring plans that specified

the number of grantee site visits to be conducted.16 We estimate that 10

percent of VAWO files17 contained documentation that the planned number

of site visits occurred. Furthermore, only 2 percent of VAWO files had

documentation that even some, but not all, of the planned site visits had

been made, while the remaining 88 percent of VAWO files18 contained no

documentation that any site visits occurred.

• Desk Reviews. 47 of 84 VAWO files contained monitoring plans that

established specific criteria for the frequency of desk reviews. However,

none of the VAWO files showed evidence that any desk reviews were

conducted.

OJP requires that grantees file semiannual progress reports and quarterly

financial reports throughout the life of a grant. Progress reports are to

supply information on the activities and accomplishments of the grantee

during the previous reporting period. Financial reports are to show the

actual expenditures and unliquidated obligations for the reporting period

(calendar quarter) and cumulative for the award. We found Byrne and

VAWO grant files in which progress reports and financial reports did not

cover the entire period of the grant and a few files with no evidence of

progress reports. We also found that progress and financial reports were

often late. Combined, these factors resulted in unaccounted periods of

time, where OJP had either no information or no up-to-date information

about grantee progress or financial activities.

For example, we compared the time periods progress and financial reports

were supposed to cover with the time periods they actually covered for

each of the Byrne and VAWO grant files we reviewed. Based on our

analysis of the grant files, we estimate that 70 percent of the Byrne grants19

had periods of time during the grant period not covered by progress

reports, and 41 percent of the Byrne grants20 had periods of time not

covered by financial reports. Likewise, we estimate that 66 percent of the

 16For VAWO site visits, our estimates are based on 51 files, not 53, because we did not

collect the necessary documentation on 2 of the files.

17The estimated range is between 3 and 22 percent.

18The estimated range is between 76 and 96 percent.

19The estimated range is between 57 and 80 percent.

20The estimated range is between 30 and 54 percent.

Progress and Financial

Reports Did Not Cover the

Entire Grant Period and

Were Often Late
Page 15 GAO-02-25 Justice Discretionary Grants

VAWO grants had periods of time during the grant period not covered by

progress reports and 36 percent of the VAWO grants had periods of time

not covered by financial reports. These gaps, cumulative over the life of

the grant, ranged from as little as 2 weeks to over 3 years for progress

reports and from 1 month to 11⁄2 years for financial reports. With regard to

progress reports, we estimate that 30 percent of Byrne grants21 and 18

percent of VAWO grants had more than 12 months that were not covered.

With regard to financial reports, we estimate that only 4 percent of grants

at both BJA and VAWO had more than 12 months that were not covered.

Our analysis also showed that a few grant files did not contain any

progress reports. For the files we reviewed, seven—three Byrne and four

VAWO—contained no progress reports. We noted that OJP awarded one

VAWO grantee two supplemental awards over the course of a 3-year

period, even though there were no progress reports in the file. In total,

these seven grant files without progress reports represent over $2 million

in grantee funds awarded over a 5-year period. Finally, we noted examples

of progress reports covering more than the required 6-month period and

noted that one VAWO progress report that was submitted to cover a 21⁄2-

year period was a half-page long. Given OJP’s requirement that progress

reports are to be submitted for each 6-month period of the grant, the fact

that reports covered periods well beyond the required 6 months raises

questions about whether a grant manager has sufficient information to

monitor progress and identify any potential grantee problems.

We asked BJA and VAWO officials why these seven grant files did not

contain any progress reports. BJA’s Acting Director at the time of our

review said that reorganizations in BJA over the last 2 years have

contributed to difficulty in ensuring complete and accurate grant files.

VAWO officials explained that one of the four grant files involved a

grantee that had some grant implementation problems that have since

been corrected and said that problems aside, the grantee had been

unaware that progress reports were required for periods of grant

inactivity. They said that another of the four grantees had been

accustomed to the reporting requirements for formula grants, but unaware

of different reporting requirements for discretionary grants. According to

VAWO officials, this situation has since been corrected and the files have

been made current. VAWO officials were unclear about why another

grantee had not submitted progress reports. However, they said that the

 21The estimated range is between 20 and 43 percent.
Page 16 GAO-02-25 Justice Discretionary Grants

one grantee that had been awarded two supplemental grants is now

scheduled for closeout because of the extended period of time the grantee

has been delinquent in submitting progress reports. In addition, VAWO

officials said that it was unacceptable for a grantee to submit a half-page

progress report covering 21⁄2 years.

Our review of grant files also showed that late reports were common.22

OJP has specific guidance that spells out when progress and financial

reports are to be filed by grantees. Progress reports are due 30 days after

the close of each previous 6-month period,23 and financial reports are to be

turned in 45 days after the end of the calendar quarter. We compared the

dates progress and financial reports were supposed to be filed by grantees

with the dates they were actually received by OJP’s Office of the

Comptroller. We estimate that 68 percent of Byrne and 85 percent of

VAWO progress reports were late. However, for both Byrne and VAWO, we

estimate that about 40 percent of all reports were late by only about a

month. Table 1 shows our estimates of the timeliness of Byrne and VAWO

progress reports.

Table 1: Estimated Timeliness of Progress Report Submissions

Percent late

Percent on time

30 days

or less

31-90

days

91-180

days

181 days

or more

Byrne 32 42 15 6 5

VAWO 15 43 21 9 12

Note 1: The percentages in this table are estimates based on a random sample of 46 Byrne and 84

VAWO discretionary grant files, representing, respectively, 209 and 361 progress reports from the

initiation of the grant through December 31, 2000. Of these reports, we excluded 7 at BJA and 13 at

VAWO because of data-related problems, such as missing submission dates. The estimates are

subject to sampling error. The 95-percent confidence intervals for the estimates are within plus or

minus 10 percent.

Note 2: Lateness is measured by the number of days beyond the deadline (30 days after the close of

each previous 6-month period) the progress report is submitted to OJP.

Source: GAO analysis.

 22We reviewed 209 BJA and 361 VAWO progress reports and 458 BJA and 811 VAWO

financial reports in the files from the initiation of the grant through December 31, 2000. Of

these reports, we excluded 7 BJA progress, 4 BJA financial, 13 VAWO progress, and 8

VAWO financial reports because of data-related problems, such as missing submission

dates.

23In 1996, OJP changed its procedures to require grantees to submit progress reports

semiannually. Before then, grantees had to submit progress reports quarterly.
Page 17 GAO-02-25 Justice Discretionary Grants

Similarly, in the case of financial reports, our review showed an estimated

53 percent of Byrne and 54 percent of VAWO financial reports were

submitted late. Similar to progress reports, about one-third of all reports

were late by 30 days or less. Table 2 shows our estimates of timeliness of

Byrne and VAWO financial reports.

Table 2: Estimated Timeliness of Financial Report Submissions

Percent late

Percent on time

30 days

or less

31-90

days

91-180

days

181 days

or more

Byrne 47 29 11 8 5

VAWO 46 29 15 6 4

Note 1: The percentages in this table are estimates based on a random sample of 46 Byrne and 84

VAWO discretionary grants, representing, respectively, 458 and 811 financial reports from the

initiation of the grant through December 31, 2000. Of these reports, we excluded 4 at BJA and 8 at

VAWO because of data-related problems, such as missing submission dates. The estimates are

subject to sampling error. The 95-percent confidence intervals for the estimates are within plus or

minus 10 percent.

Note 2: Lateness is measured by the number of days beyond the deadline (45 days after the close of

each previous quarter) the financial report is submitted to OJP.

Source: GAO analysis.

OJP’s Office of the Comptroller also found problems similar to those we

identified regarding financial reports. As mentioned earlier, the Office of

the Comptroller does periodic financial reviews of the official grant file.

We examined Comptroller records for 22 grants also covered in our review

and found they identified 8 Byrne and 9 VAWO files that were missing

some financial reports and 5 Byrne and 8 VAWO files in which financial

reports were late. We did not determine what was done to follow up on the

late or missing financial reports found during these financial reviews.

However, Comptroller procedures call for contacting the grant manager or

grantee to request copies of documents that may be missing from the file

and to ensure that all documentation related to the financial review is

included in the official grant file before the review is closed.

Our review also showed that BJA and VAWO grant managers did not

always document key closeout activities for those files we examined. OJP

requires that grants be closed in a timely manner and considers the

process to be one of the most important aspects of grant administration.

Closing out grants is the final step in a process by which OJP ensures that

all required financial and progress reports and final accounting of federal

funds have been received. The timeframe for completion of closeout is no

more than 180 days after the end of the grant project. According to OJP

Byrne and VAWO Closeout

Documents Missing
Page 18 GAO-02-25 Justice Discretionary Grants

guidance, as part of the closeout process, the grant manager is to review

the grant file and contact the grantee about the upcoming grant end date

and final report submissions. The grant manager is to use the closeout

checklist as a means of ensuring that all closeout requirements—the

grantee’s submission of final progress and financial reports—are met.

We identified 19 closed Byrne grants and 3 closed VAWO grants that ended

between September 30, 1999, and August 31, 2000.24 There were not

enough closed cases in our sample to ensure that our assessment was

representative of all grant closeouts. However, our limited review showed

that some grant files did not contain required closeout materials. For

example, for the Byrne grants:

• 15 files did not contain documentation of the precloseout contact with the

grantee; 25

• 9 files did not contain closeout checklists;

• 10 files did not contain the final narrative progress report; and

• 7 files did not contain the final financial report.

For the VAWO grants:

• 3 files did not contain documentation of the precloseout contact with the

grantee;

• 3 files did not contain closeout checklists;

• 2 files did not contain the final narrative progress report; and

• 1 file did not contain the final financial report.

 24In order to take into account the minimum 180 days OJP allows bureaus and offices to

complete closeout activities, we used August 31, 2000, as the cutoff date for our analysis of

BJA closeout activities. Using this cutoff date, we identified an additional 2 grants at VAWO

that appeared to be closed. However, according to VAWO, the 2 grants were not actually

closed, but rather, had been given extensions. VAWO officials acknowledged that the

required documents extending the grant period were not in the files. These grants were

excluded from our closed grant analysis.

25We did not collect information for one of the files on precloseout contacts; therefore, this

part of the review covered 18, not 19, cases.
Page 19 GAO-02-25 Justice Discretionary Grants

BJA and VAWO officials acknowledged that their file maintenance and

documentation may not have always been in compliance with OJP

monitoring requirements. Officials at both agencies stated that, in some

instances, lack of documentation was because of an increased workload

among grant managers. In addition, VAWO officials said that since VAWO’s

inception, VAWO grant managers have had the responsibility to not only

monitor an increasing volume of grants, but also to develop and

implement several new grant programs.26 In commenting on a draft of this

report, the Assistant Attorney General stated BJA grant managers have

had similar responsibilities. The Assistant Attorney General also

commented that one reason for VAWO’s lack of documentation regarding

site visits might be a past practice by which all VAWO grant managers

memorandums included a standard monitoring plan that was developed in

fiscal year 1995, when VAWO was responsible for monitoring one formula

and one small discretionary grant program.

Regardless, officials from both BJA and VAWO stated that the monitoring

activities may still be taking place, even though they are not documented

consistently. When asked how one would know whether a desk review

had been done, one BJA official told us that desk reviews were not a

specific process, rather they were the type of activities that grant

managers did on a day-to-day basis. He added that since BJA had no

formalized process for conducting desk reviews, no documentation was

required of the grant managers upon completion. Nonetheless, OJP’s

guidance for the period covered by our review stated that a desk review

form is to be prepared periodically to note, among other things, all

contacts, reports, and product reviews. The form is also to include issues,

accomplishments, and problems, noting recommended solutions.

BJA’s Acting Director at the time of our review told us that oversight of

grants can and has suffered through changes at BJA, including

reorganizations within BJA and the increased number of grants and

greater workload for BJA grant managers. He said that there is no question

that, as mentioned earlier, reorganizations contributed to the difficulty in

ensuring complete and accurate grant files and cited transfers of grant

files among grant managers as one reason why files were inaccurate or

incomplete. He pointed out that BJA has made some changes, including

the drafting of new policies and procedures, that are designed to assist

 26For example, the Higher Education Amendments of 1998 established the Grants to

Combat Violence Crime Against Women on Campuses Program (20 U.S.C. 1152).

BJA and VAWO Officials

Acknowledge Lack of

Consistent Compliance

With OJP Requirements
Page 20 GAO-02-25 Justice Discretionary Grants

grant managers in their grant responsibilities. For example, BJA’s draft

procedures called for desk reviews to be performed by grant managers

every 6 months or when files were transferred among grant managers.

These reviews were to require that each grant manager fill out a

checklist—covering such things as the completeness of grant paperwork

and the timeliness of progress and financial reports—that upon

completion, was to be reviewed by a branch chief. According to the Acting

Director at the time of our review, BJA’s guidance, which was undated,

had been drafted sometime before July 2000, but had since been subsumed

into OJP’s January 2001 update to its grant monitoring procedures. At the

time of our review, it was unclear whether BJA had put any of these

procedures into practice. In commenting on a draft of this report, the

Assistant Attorney General noted that BJA has indicated that it expects to

put these procedures into practice in fiscal year 2002.

In those same comments, the Assistant Attorney General also stated that

like BJA, VAWO has been working on developing policies and procedures

for monitoring grantees more effectively. For example, she stated that a

VAWO Monitoring Working Group was formed in spring 2001. The group is

working to develop a risk-based assessment tool to develop more realistic

monitoring plans; pre-, post-, and on-site protocols for site visits; a

standard site visit report form; and a comprehensive training program on

monitoring for new employees. Also, according to the Assistant Attorney

General, VAWO has developed a desk review checklist that will begin to be

used in fiscal year 2002.

OJP requires documentation of grant monitoring activities to provide

assurance to OJP grant managers and supervisors that appropriate

oversight of grant activities is taking place. It is possible that grant

managers are conducting grant monitoring activities even if no

documentation exists. However, without documentation, neither OJP,

BJA, VAWO, nor we are positioned to tell with any certainty whether such

monitoring occurred. The Comptroller General’s internal control

standards27 require that all transactions and other significant events be

clearly documented and that the documentation be readily available for

examination. Appropriate documentation is an internal control activity to

help ensure that management’s directives are carried out. Without such

documentation, OJP, BJA, and VAWO have no assurance that grants are

 27Standards for Internal Control in the Federal Government (GAO/AIMD-00-21.3.1, Nov.

1999).
Page 21 GAO-02-25 Justice Discretionary Grants

meeting their goals and funds are being used properly. In addition, such

documentation is essential to systematically address grant performance

problems.

BJA and VAWO are not positioned to systematically determine grant

managers’ compliance with monitoring requirements because

documentation about monitoring activities is not readily available. BJA

officials told us that they do not have a management information system to

collect and analyze data that would help them oversee the monitoring

process. Instead, they rely on staff meetings and informal discussions with

staff to oversee grant monitoring activities and identify potential grantee

problems. As discussed earlier, BJA’s Acting Director at the time of our

review acknowledged that BJA had experienced some documentation

problems and told us that, in addition to drafting the aforementioned BJA

guidelines, BJA had begun to modify an officewide management

information system to capture data on monitoring activities. According to

BJA officials, the enhanced system is to enable grant managers to enter

data on such activities as site visits and phone contacts so that they can be

tracked. However, at the time of our field work, the system was still in

developmental stages. In commenting on a draft of this report, the

Assistant Attorney General stated that the monitoring portion of this

system was deployed in October 2001.

Like BJA, VAWO does not have an overall management information

system to track monitoring activities. VAWO officials said that they hold

weekly staff meetings during which they rely on their grant managers to

proactively identify and discuss any grant problems or monitoring issues.28

They added that VAWO has developed a computerized site visit tracking

sheet that provides information about the details of grant managers’ onsite visits. A VAWO official said that information reported in site visit

reports is shared at staff meetings and is accessible to all staff on VAWO’s

internal computer system.29 VAWO officials also indicated that they are in

 28In commenting on a draft of this report, the Assistant Attorney General noted that VAWO

staff receive feedback from grantees and those receiving services from grantees, as well as

attend training events in which grantees participate, all of which assist VAWO staff in

monitoring grants.

29OJP uses site visit data to compile an OJP-wide report for the Attorney General. However,

according to an official, OJP does not uniformly compile these data for all types of grants

awarded by OJP. For example, whereas OJP reports on VAWO site visits, it does not report

on site visits for BJA discretionary grants.

BJA and VAWO Are

Not Positioned to

Systematically

Determine Staff

Compliance With

Monitoring

Requirements and

Assess Overall

Performance
Page 22 GAO-02-25 Justice Discretionary Grants

the process of developing a management information system that will

track, in addition to site visits, other monitoring activities such as the

submission of progress and financial reports. However, like BJA, VAWO’s

system was still in the developmental stages at the time of our review.

BJA and VAWO also do not appear to be routinely using available OJPwide data on late progress and financial reports that could help them

identify potential grantee documentation problems. As mentioned earlier,

the Office of the Comptroller has primary responsibility for carrying out

the monitoring of the fiscal aspects of grants awarded by OJP bureaus and

program offices, and the Control Desk issues monthly reports on whether

grantee progress and financial reports are late. These reports are to be

forwarded to the administrative officers in the bureaus and program

offices. According to OJP’s Chief of Staff at the time of our review, once

the monthly report is distributed, bureaus and program offices are

responsible for determining what action to take regarding delinquent

reports. BJA and VAWO program officials told us that they were aware of

the monthly report, but the Acting Director of VAWO’s Program

Management Division told us that VAWO probably uses the report every

other month. A BJA supervisor indicated that he did not receive the

reports, but he could get it, as needed, from the Office of the Comptroller.

The lack of systematic data associated with program monitoring activities

and the documentation problems we observed raise questions about

whether BJA and VAWO are positioned to measure their performance

consistent with the Government Performance and Results Act of 1993. For

example, in its Fiscal Year 2000 Performance Report and Fiscal Year 2002

Performance Plan, DOJ articulated a strategic goal to “prevent and reduce

crime and violence by assisting state, tribal, local and community-based

programs.” DOJ’s performance report and plan list various annual goals

and performance measures along with performance data needed to gauge

performance, including three program targets and performance measures

for VAWO formula and discretionary grant programs. To gauge annual

performance for the three VAWO targets, the plan and report state that

needed performance data

• will be obtained from grantee progress reports, on-site monitoring, and

VAWO program office files;

• will be verified and validated through a review of grantee progress reports,

telephone contacts with grantees, and on-site monitoring of grantee

performance by grant program managers; and

• contain no known limitations.
Page 23 GAO-02-25 Justice Discretionary Grants

Although the DOJ performance report and plan state that there are no

known data limitations, inconsistent documentation and the lack of

systematic data could be a serious limitation that hinders VAWO’s ability

to measure whether it is achieving its goals. VAWO officials told us that

they are not satisfied with the current performance measures because they

do not believe they are meaningful for measuring program outcomes. They

said that they have begun to work with OJP’s Office of Budget and

Management Services and an outside contractor to develop new measures.

They added that their goal is to have these new measures available for the

fiscal year 2003 GPRA performance plan.

Over the last few years, we and others, including OJP, have identified

various grant monitoring problems among OJP’s bureaus and offices. OJP

has begun to work with its bureaus and offices, such as BJA and VAWO, to

address these problems, but it is too early to tell whether its efforts will be

enough to resolve many of the issues that we and others, including OJP,

have identified.

Since 1996, we have testified and issued reports that document grant

monitoring problems among some of OJP bureaus and offices. In 1996, we

testified on the operations of the Office of Juvenile Justice and

Delinquency Prevention.30 We found that almost all of the official

discretionary grant files we reviewed contained monitoring plans, but

there was little evidence that monitoring had occurred. More recently, in

an October 2001 report, we observed many of the same issues concerning

OJJDP’s lack of documentation of its monitoring activities.31 Also, in 1999,

we issued a report that, among other things, addressed how OJP’s

Executive Office for Weed and Seed monitors local Weed and Seed sites to

ensure that grant requirements are met.32 We found that, during fiscal year

1998, grantees had not submitted all of the required progress reports and

grant managers had not always documented the results of their on-site

monitoring visits.

 30Juvenile Justice: Selected Issues Relating to OJJDP’s Reauthorization

(GAO/T-GGD-96-103, May 8, 1996).

31GAO-02-65.

32Federal Grants: More Can Be Done to Improve Weed and Seed Program Management

(GAO/GGD-99-110, July 16, 1999).

OJP’s Efforts to

Resolve Continuing

Grant Monitoring

Problems

Problems With OJP Grant

Monitoring Are Not New
Page 24 GAO-02-25 Justice Discretionary Grants

OJP has also identified problems with grant monitoring. In 1996, an OJPwide working group, established at the request of the Assistant Attorney

General, issued a report on various aspects of the grant process, including

grant administration and monitoring. Among other things, the working

group found that

• the administration of grants, including monitoring, was not standardized

within OJP;

• given the monitoring resources available, monitoring plans were overly

ambitious, the usual result being failure to attain the level of monitoring

indicated in the plans; and

• an OJP-wide monitoring tracking system was needed to document all

monitoring activities on an individual grant and facilitate control of the

monitoring process.

The working group recommended that OJP establish another working

group to develop detailed operating procedures, giving special attention to

the issue of grant monitoring.

Almost 4 years later, in February 2000, Dougherty and Associates, under

contract, delivered a report to OJP containing similar findings.33 The report

stated that that OJP lacks consistent procedures and practices for

performing grant management functions, including grant monitoring,

across the agency. For example, according to the report, no formal

guidance had been provided to grant managers on how stringent or

flexible they should be with grantees in enforcing deadlines, due dates,

and other grant requirements. Also, the report stated that the official grant

files were often not complete or reliable. To improve grant monitoring, the

contractor recommended, among other things, that OJP develop an

agencywide, coordinated and integrated monitoring strategy; standardize

guidelines and procedures for conducting site-visits, product reviews, and

other monitoring activities; and mandate the timeliness and filing of

monitoring reports.

The DOJ’s Office of Inspector General has also identified and reported on

OJP-wide grant management and monitoring problems. For example, in

December 2000, the Inspector General identified grant management as one

of the 10 major management challenges facing DOJ. The Inspector General

 33Final Report of Findings & Recommendations for Improvement of the Grant

Management Process (Alexandria, VA: Dougherty and Associates, Feb. 2000).
Page 25 GAO-02-25 Justice Discretionary Grants

stated that DOJ’s multibillion-dollar grant programs are a high risk for

fraud, given the amount of money involved and the tens of thousands of

grantees. Among other things, the Inspector General said that past reviews

determined that many grantees did not submit the required progress and

financial reports and that program officials’ on-site monitoring reviews did

not consistently address all grant conditions.

OJP has begun to work with bureaus and offices to resolve some of the

problems it and others have identified, but it is much too early to tell how

effective these efforts will be in resolving these issues. In its Fiscal Year

2000 Performance Report and Fiscal Year 2002 Performance Plan

developed under GPRA, OJP established a goal to achieve the effective

management of grants. Among other things, DOJ plans to achieve this goal

by continued progress toward full implementation of a new Grant

Management System as a way of standardizing and streamlining the grant

process. According to the performance report and performance plan, GMS

will assist OJP in setting priorities for program monitoring and facilitate

timely program and financial reports from grantees.

OJP’s Chief of Staff at the time of our review told us that, in his view, the

only way to ensure that staff consistently document their monitoring

activities is to require grant managers to enter information about their

monitoring activities, when they occur, into an automated system, like

GMS. He said that currently, OJP runs the risk of losing or misplacing key

documentation, especially since documents are kept in two files physically

maintained by two organizations in different locations—one, the official

file maintained by the Office of the Comptroller, and the other, the grant

manager’s file maintained by the program office. He said that the new

system currently covers grants for some OJP organizations up to the

award stage, but that OJP’s goal is to include tracking information about

all stages of the grant process from preaward through closeout.34

Although GMS may ultimately help OJP better manage the grant

administration process, DOJ’s Fiscal Year 2000 Performance Report and

Fiscal Year 2002 Performance Plan does not state when GMS will be

expanded—either to all of the OJP components or to include the full range

and scope of monitoring activities. Regarding the latter, OJP’s Director of

Office of Budget and Management Services indicated that it is unlikely that

 34Appendix II illustrates the stages of the grant process.

Too Early to Gauge

Effectiveness of OJP’s

Efforts to Resolve Grant

Monitoring Problems
Page 26 GAO-02-25 Justice Discretionary Grants

GMS will cover the full range of monitoring activities; instead, OJP would

be more likely to develop a monitoring management information system to

capture monitoring data that would link to GMS.35 The Director said that

OJP has formed an OJP-wide working group to further study data issues

related to monitoring activities, but the group is in its preliminary stages

and has yet to develop a charter to define its activities.

OJP has also been working on two key efforts to enhance its ability to

better control grant administration. One of these initiatives, “Operation

Closeout,” was a pilot project announced in February 2000 by OJP’s

Working Group on Grant Administration that was to, among other things,

accelerate the grant closeout process through revised closeout guidelines

and elevate the importance of the closeout function as a required

procedure in the administration of grants.36 In November 2000, the working

group announced that it had realized several of the Operation’s objectives

and, working with the Office of the Comptroller, was able to reduce the

backlog of grants, including some managed by BJA and VAWO, that were

eligible to be closed but had not been closed. According to the Chairman

of the working group, this operation closed out 4,136 outstanding grants

over a 6-month period, resulting in over $30 million in deobligated funds.

In September 2001, the Chairman said that OJP was going to initiate

another closeout operation based on the success of the pilot.

Another OJP initiative involved the development and issuance of new OJPwide guidance for grant administration, including grant monitoring. As

mentioned earlier, in January 2001, OJP released Grant Management

Policies and Procedures Manual to update and codify OJP’s current

policies and procedures regarding its business practices.37 According to

OJP officials, the new guidance was developed at the direction of the

former Assistant Attorney General to address overall concerns about

weaknesses in the 1992 version. The guidance was developed over a

period of about two years, with the goal of reengineering the grant

management process based on the best practices of bureaus and offices

throughout OJP. For example, the changes include some provisions

pertaining to some of the aforementioned closeout activities--grantees are

 35In commenting on a draft of this report, the Assistant Attorney General noted that the

Office of the Comptroller already utilizes a financial monitoring tracking system to manage

financial monitoring activities and capture financial monitoring information.

36The working group was comprised of staff members from OJP’s bureaus and offices.

37This document superseded the 1992 Handbook.
Page 27 GAO-02-25 Justice Discretionary Grants

now given 120 days to submit final financial reports (instead of 90 days).

Also, grant managers are given greater latitude to close out a grant if they

have been unsuccessful in obtaining the final financial report from the

grantee.

OJP trained over 300 grant managers during summer 2001 and, according

to the Chairman of the working group, intends to train supervisors about

the new guidance in fall 2001. OJP also has drafted and plans to send a

questionnaire to recently trained grant managers to identify any issues or

problems with using the online manual and to identify potential training

interest and topics. OJP plans to develop and send a similar questionnaire

to supervisors once they are trained. However, the Chairman indicated

that there are no plans to test or systematically monitor compliance with

the new guidelines to ensure that grant managers are fulfilling their

responsibilities. He said that OJP had not contemplated testing or

systematic monitoring because of other initiatives currently under way.

Because BJA and VAWO discretionary grant files were insufficiently

documented neither OJP, BJA, VAWO, or we can determine the level of

monitoring being performed by grant managers as required by OJP and the

Comptroller General’s internal control standards. BJA and VAWO

supervisors rely on staff meetings and discussions with staff to alert them

to grantee problems or grant monitoring issues, but these activities are not

sufficient to ensure that required monitoring is taking place or that the

proper documentation is occurring. Furthermore, BJA and VAWO do not

have readily available data on most monitoring activities that would help

them determine grant managers’ compliance with OJP guidelines, and

even when data are available, it is not clear that supervisors use the data

to ensure that monitoring activities occurred. The lack of systematic data,

combined with poor documentation, limits BJA and VAWO’s ability to

manage the grant monitoring process so that they can determine whether

grant managers are monitoring grantees, and if not, why not, or if so, why

are they not documenting their activities. It also hinders BJA and VAWO’s

ability to measure their performance consistent with GPRA, especially

given that DOJ is relying on data collected through grant monitoring to

measure the Department’s performance for many of its grant programs.

Furthermore, it places BJA and VAWO at risk in ensuring that the millions

of dollars in discretionary grant funds that they distribute are effectively

and responsibly managed.

Grant monitoring problems have been long-standing at DOJ, and although

OJP has taken steps intended to resolve some of them, it is too early to tell

whether these steps will effectively solve the types of documentation

Conclusions
Page 28 GAO-02-25 Justice Discretionary Grants

problems that we and others have identified. Automation of the grant

management process, particularly in regard to grant monitoring, holds

some promise if OJP takes steps to ensure that all monitoring activities are

consistently recorded and maintained in a timely manner. However,

current and future efforts will be futile unless OJP and its bureaus and

offices, such as BJA and VAWO, periodically test grant manager

compliance with OJP requirements and take corrective actions to enforce

those requirements.

To facilitate and improve the management of program monitoring, we

recommend that the Attorney General direct BJA and VAWO to review

whether the documentation problems we identified were an indication of

grant monitoring requirements not being met or of a failure to document

activities that did, in fact, take place. If monitoring requirements are not

being met, we recommend that the Attorney General direct BJA and

VAWO to determine why this is so and to take into account those reasons

as they consider solutions for improving compliance with the

requirements. If it is determined that required monitoring is taking place

but is not being documented, we recommend that the Attorney General

take steps to direct BJA and VAWO to periodically articulate and enforce

clear expectations regarding documentation of monitoring activities.

We also recommend that the Attorney General direct OJP to study and

recommend ways to establish an OJP-wide approach for systematically

testing or reviewing official and program files to ensure that the grant

managers in its various bureaus and offices are consistently documenting

their monitoring activities in accordance with OJP requirements and the

Comptroller General’s internal control standards. Furthermore, we

recommend that the Attorney General direct OJP to explore ways to

electronically compile and maintain documentation of monitoring

activities to facilitate (1) more consistent documentation among grant

managers; (2) more accessible oversight by bureau and program office

managers; and (3) sound performance measurement, consistent with

GPRA.

We provided a copy of a draft of this report to the Attorney General for

review and comment. In a November 9, 2001, letter, the Assistant Attorney

General commented on the draft. Her comments are summarized below

and presented in their entirety in appendix III.

The Assistant Attorney General said that overall, the report provides

useful information in highlighting management and monitoring activities in

Recommendations for

Executive Action

Agency Comments

and Our Evaluation
Page 29 GAO-02-25 Justice Discretionary Grants

need of improvement. She noted that BJA and VAWO have already taken

steps to address the recommendations for follow-up action included in the

draft report. For example, the Assistant Attorney General said that BJA

has taken steps to, among other things, expand its grants tracking system

to include tracking of staff and grantee contacts and instituted a policy

that a desk review be conducted twice per year for all grants. With regard

to VAWO, the Assistant Attorney General said that, among other things,

VAWO had established a monitoring working group tasked with

developing monitoring policies and procedures for monitoring grantees

more effectively, including more realistic monitoring plans and a

standardized site visit reporting format.

We acknowledge that BJA and VAWO appear to be taking steps in the right

direction toward resolving some of the issues we identified. However,

until these actions become operational, BJA and VAWO will not be able to

determine whether the problems we identified constitute either a failure to

carry out required monitoring activities or a failure to document

monitoring activities. Once BJA and VAWO make this determination, they

will be better positioned to consider what additional steps need to be

taken, such as articulating and enforcing clear expectations regarding the

documentation of monitoring activities.

In her letter, the Assistant Attorney General did not address our

recommendations that OJP (1) study and recommend ways to establish an

OJP-wide approach for systematically testing or reviewing official and

program grant files or (2) explore ways to electronically compile and

maintain documentation of monitoring activities. Although the steps BJA

and VAWO are taking may help them better understand and act upon

problems associated with the documentation of monitoring activities, the

steps discussed in the Assistant Attorney General’s letter appear to be

actions specific to those organizations. Thus, it is unclear whether and to

what extent those actions can be applied throughout OJP. Without a more

focused and concerted effort to implement an OJP-wide approach for

systematically testing or reviewing program grant files and an automated

approach to compile and document monitoring data, OJP could continue

to face the grant monitoring problems we and others, including OJP, have

identified.

In addition to the above comments, the Assistant Attorney General made a

number of suggestions related to topics in this report. We have included

the Assistant Attorney General's suggestions in the report, where

appropriate. Also, the Assistant Attorney General provided other
Page 30 GAO-02-25 Justice Discretionary Grants

comments for which we did not make changes. See appendix III for a

more detailed discussion of the Assistant Attorney General's comments.

We are sending copies of this report to the Chairmen of the Senate

Judiciary Committee and its Subcommittee on Youth Violence; Chairmen

and Ranking Minority Members of the House Committee on Education and

the Workforce; Attorney General; OJP Assistant Attorney General; BJA

Administrator; VAWO Administrator; and Director, Office of Management

and Budget. We will also make copies available to others on request.

If you or your staff have any questions about this report, please contact

John F. Mortin or me at (202) 512-8777. Key contributors to this report are

acknowledged in appendix IV.

Laurie E. Ekstrand

Director, Justice Issues
Appendix I: Size and Growth of OJP, BJA, and

VAWO Budgets and BJA and VAWO

Discretionary Grant Programs

Page 31 GAO-02-25 Justice Discretionary Grants

The Office of Justice Programs (OJP) and its bureaus and offices,

including the Bureau of Justice Assistance (BJA) and the Violence Against

Women Office (VAWO), experienced budget growth in the latter half of the

1990s, following the passage of the 1994 Crime Act.1

 According to data we

obtained from OJP, in the 1990s, the yearly number of BJA discretionary

awards and total dollar amount of those awards fluctuated somewhat, but

generally increased. The number of Byrne discretionary grant awards have

decreased since a high point in fiscal year 1994; however, the total yearly

dollar amount has increased overall. Furthermore, while the yearly

number of Byrne awards and the dollar amount of those awards generally

increased, there were some yearly decreases. Following the creation of

VAWO in 1995, the yearly number of discretionary awards and total dollar

amount of those awards increased overall.

According to OJP data, from 1990 through 2000, OJP’s budget grew, in

constant fiscal year 2000 dollars, by 323 percent, from about $916 million

in fiscal year 1990 to nearly $3.9 billion in fiscal year 2000.2 Our analysis of

the OJP data also showed that BJA’s budget grew during the 1990s, but to

a lesser extent than OJP’s. BJA’s budget increased by 173 percent, from

about $618 million in fiscal year 1990 to nearly $1.7 billion in fiscal year

2000. In fiscal year 1996, OJP and BJA’s budget increased sharply after

enactment of the 1994 Crime Act. BJA’s budget as a percentage of OJP’s

budget decreased from about 67 percent in fiscal year 1990 to 57 percent

in fiscal year 1996. Following its creation in 1995, VAWO’s budget

increased by 42 percent, from $176 million in fiscal year 1996, its first full

year of funding, to about $250 million in fiscal year 2000. 3 Figure 2 shows

the growth in overall OJP, BJA, and VAWO budgets, illustrating how BJA

and VAWO fit into the overall OJP budget from fiscal years 1990 through

2000.

 1

Violent Crime Control and Law Enforcement Act of 1994 (P.L. 103-322).

2

All budget figures in this appendix, unless otherwise noted, are adjusted to constant fiscal

year 2000 dollars.

3

VAWO was first funded under the Violence Against Women Act of 1994, Title IV of the

Crime Act (P.L. 103-322).

Appendix I: Size and Growth of OJP, BJA, and

VAWO Budgets and BJA and VAWO

Discretionary Grant Programs

Budget Increases at

OJP, BJA, and VAWO

in the 1990s
Appendix I: Size and Growth of OJP, BJA, and

VAWO Budgets and BJA and VAWO

Discretionary Grant Programs

Page 32 GAO-02-25 Justice Discretionary Grants

Figure 2: Overall OJP and BJA and VAWO Yearly Budget Resources

Note1: According to OJP budget officials, yearly figures include all funds appropriated to OJP,

transfers from other agencies, and receipts from the Crime Victim Fund, which is derived not from tax

dollars, but from fines and penalties paid by federal criminal offenders. However, the yearly figures do

not include grants awarded and administered by OJP bureaus and offices for other federal agencies

(including other DOJ agencies) under reimbursable agreements. Also, the yearly amounts do not

include direct appropriations for OJP management and administration. The large funding increase for

fiscal year 1996 resulted from the Omnibus Consolidated Recissions and Appropriations Act of 1996,

which appropriated funds authorized by the Violent Crime Control and Law Enforcement Act of 1994.

Note 2: The budget amounts for each fiscal year are adjusted to constant fiscal year 2000 dollars.

Source: OJP Office of Budget and Management Services.

For this report, we analyzed the growth in the number and dollar amount

of discretionary awards each year by BJA and VAWO from 1990 through

2000, based on data provided by OJP. From 1990 to 2000, the number of

BJA Byrne discretionary awards increased by about 83 percent—from 54

in fiscal year 1990 to 99 in fiscal year 2000. Overall, the total number of

BJA discretionary awards, including Byrne discretionary awards,

increased by about 320 percent—from 65 in fiscal year 1990 to 273 in fiscal

year 2000. As shown in figure 3, the overall increase in BJA discretionary

awards for the 11-year period we analyzed was moderate, with some

yearly decreases.

Discretionary Grant

Award Increases at

BJA and VAWO in the

1990s
Appendix I: Size and Growth of OJP, BJA, and

VAWO Budgets and BJA and VAWO

Discretionary Grant Programs

Page 33 GAO-02-25 Justice Discretionary Grants

Figure 3: Overall Yearly BJA Discretionary Awards

Source: OJP Office of the Comptroller.

Along with the increased number of discretionary awards by BJA, the

yearly total dollar amount of those awards also increased. As illustrated in

figure 4 below, the total dollar amount of Byrne discretionary awards

increased, in constant fiscal year 2000 dollars, by 256 percent—from about

$19 million in fiscal year 1990 to almost $69 million in fiscal year 2000. The

total dollar amount of all BJA discretionary awards, including Byrne

discretionary awards, increased even more—by about 422 percent—from

just over $36 million in fiscal year 1990 to nearly $189 million in fiscal year

2000. The increase in the yearly total dollar amount of Byrne discretionary

awards was moderate, with some yearly decreases. For all BJA

discretionary awards, particularly non-Byrne discretionary awards, the

total dollar amount increases were substantial in fiscal years 1998 through

2000. Figure 4 shows the dollar amount of BJA discretionary awards

(Byrne and non-Byrne) from fiscal year 1990 to 2000.
Appendix I: Size and Growth of OJP, BJA, and

VAWO Budgets and BJA and VAWO

Discretionary Grant Programs

Page 34 GAO-02-25 Justice Discretionary Grants

Figure 4: Dollar Amount of Overall BJA Discretionary Awards

Note: The award amounts for each fiscal year are adjusted to constant fiscal year 2000 dollars.

Source: OJP Office of the Comptroller.

Data provided by OJP showed that at VAWO, since its inception in 1995,

the yearly total number and dollar amount of its discretionary awards also

increased. As shown in the figures below, the yearly number of VAWO

discretionary awards increased by about 362 percent—from 92 in fiscal

year 1996, the first full year of funding to 425 in fiscal year 2000. In

addition, the yearly dollar amount of VAWO discretionary awards

increased by about 940 percent—from just over $12 million in fiscal year

1996, the first full year of funding, to about $125 million in fiscal year 2000.

Figure 5 shows the number of VAWO discretionary awards for each fiscal

year from 1995 to 2000. Figure 6 shows the dollar amount of VAWO

discretionary awards for the same period.
Appendix I: Size and Growth of OJP, BJA, and

VAWO Budgets and BJA and VAWO

Discretionary Grant Programs

Page 35 GAO-02-25 Justice Discretionary Grants

Figure 5: Number of Yearly VAWO Discretionary Awards

Source: OJP Office of the Comptroller.

Figure 6: Dollar Amount of VAWO Discretionary Awards

Note: The award amounts for each fiscal year are adjusted to constant fiscal year 2000 dollars.

Source: OJP Office of the Comptroller.
Appendix II: Stages of the Discretionary

Grant Process

Page 36 GAO-02-25 Justice Discretionary Grants

OJP awards two types of grants: formula and discretionary. OJP formula

grants are awarded directly to state governments, which then make

subawards to state and local unites of government. Discretionary grants

can be awarded to states, local units of government, Indian tribes and

tribal organizations, individuals, educational institutions, private nonprofit

organizations, and private commercial organizations. With some

discretionary grant programs, OJP has some flexibility in selecting topics

as well as grantees. Some discretionary awards are competitive, while

others are non-competitive, owing to limited amount of funds available to

a limited number of potential recipients. Figure 7 summarizes the life of a

discretionary grant from application to closeout.

Figure 7: Life of a Discretionary Grant

Once the application for the discretionary grant is accepted, OJP guidance

requires the grant manager to prepare a grant manager’s memorandum,

which OJP reviews before the award is made. The memorandum is to

consist of the following, among other things:

• an overview of the project;

• a detailed description of what type of activities the grantee plans to

implement;

• a discussion of the financial justification of the grant funds and of the costeffectiveness evaluation of the application; and

• a discussion of past assessments, where applicable.

Appendix II: Stages of the Discretionary

Grant Process

Grantee activity

is comprised of an

implementation plan,

milestones, and

deliverables.

Grant manager's

memorandum

is received, prepared,

and approved.

Application Assessment Monitoring/Progress

Requirements include

• Monitoring activities

 for both initial and 

 supplemental grants,

 including

 • site visits,

 • desk reviews, and

 • telephone contacts 

 and 

• Progress reports

 and financial reports

(from the grantee).

Supplemental Award(s) Closeout

Supplemental awards

occur at this phase

only if requested.

Initial Award

Monitoring plan

is a part of the grant

manager's memorandum,

and it lays out

• the type of monitoring

and

• the frequency.

Closeout

requirements include

• final financial report;

and

• final progress report.

Live Grant
Appendix II: Stages of the Discretionary

Grant Process

Page 37 GAO-02-25 Justice Discretionary Grants

As part of a grant manager’s memorandum, each grant manager is to

prepare a monitoring plan. The plan is to contain information on who will

conduct the monitoring, how it will be done, and when and what type of

monitoring activities are planned. Monitoring information is to be

collected using such techniques as on-site visits, telephone calls, and desk

reviews, which are reviews to ensure that the grant files are complete and

that the grantee is in compliance with the program guidelines. Also, OJP

guidance requires the grantee to file specific reports with the Office of the

Comptroller: semiannual progress reports that summarize project

activities and quarterly financial reports that provide an accounting of

grant expenditures. The Office of the Comptroller is to forward the reports

to grant managers.

OJP is to apply the same process to supplemental awards as it does to the

original award of a grant. When the grantee requests an extension, thus

requiring supplemental funding, the grantee must repeat the award

application process, and more time and money is expended.

At the end of the grant period, the grant manager is required to close out

the grant according to OJP guidance. Closing out grants is the final step in

a process by which OJP ensures that all required financial and progress

reports and a final accounting of federal funds have been received. Figure

8 illustrates the grant process, including supplemental or extended

funding.
Appendix II: Stages of the Discretionary

Grant Process

Page 38 GAO-02-25 Justice Discretionary Grants

Figure 8: Supplemental Award Process and Time Frame

1st Year 2nd Year 3rd Year 4th Year 5th Year 6th Year 7th Year 8th Year

Original

award

First

supplemental

award

Second

supplemental

award

Third

supplemental

award

Time frame

Process

Process

repeated

Process

repeated

Application

Assessment

Award

Live grant

Supplemental

Close out

Application

Assessment

Award

Live grant

Supplemental

Application

Assessment

Award

Live grant

Supplemental

Process

repeated

Application

Assessment

Award

Live grant

Supplemental

Life of a Grant
Appendix III: Comments From the

Department of Justice

Page 39 GAO-02-25 Justice Discretionary Grants

Appendix III: Comments From the

Department of Justice

Note: GAO comments

supplementing those in

the report text appear at

the end of this appendix.
Appendix III: Comments From the

Department of Justice

Page 40 GAO-02-25 Justice Discretionary Grants
Appendix III: Comments From the

Department of Justice

Page 41 GAO-02-25 Justice Discretionary Grants

See comment 5.

See comment 4.

See p. 19.

See comment 3.

See comment 2.

See comment 1.
Appendix III: Comments From the

Department of Justice

Page 42 GAO-02-25 Justice Discretionary Grants

See comment 7.

See comment 2.

See footnote 28.

See comment 6.
Appendix III: Comments From the

Department of Justice

Page 43 GAO-02-25 Justice Discretionary Grants

See p. 20.

See comment 8.

Now footnote 9.
Appendix III: Comments From the

Department of Justice

Page 44 GAO-02-25 Justice Discretionary Grants

Now on p. 21.

Now on p. 21.

See comment 10.

Now on p. 19.

Now on p. 19.

See comment 9.
Appendix III: Comments From the

Department of Justice

Page 45 GAO-02-25 Justice Discretionary Grants

See comment 13.

See comment 1.

See comment 12.

See comment 11.

See footnote 34.

Now on pp. 21-22.

Now on p. 21.
Appendix III: Comments From the

Department of Justice

Page 46 GAO-02-25 Justice Discretionary Grants

See comment 14.

Now on pp. 37-38.

Now on p. 36.
Appendix III: Comments From the

Department of Justice

Page 47 GAO-02-25 Justice Discretionary Grants
Appendix III: Comments From the

Department of Justice

Page 48 GAO-02-25 Justice Discretionary Grants
Appendix III: Comments From the

Department of Justice

Page 49 GAO-02-25 Justice Discretionary Grants

The following are GAO’s comments on the Department of Justice’s

November 9, 2001, letter.

1. We report on the growth in the number and dollar amount of VAWO

discretionary grants since fiscal year 1996 in appendix I (see pp. 34-35).

2. We have amended the Background section of the report to add this

information (see p. 6).

3. We disagree. As we stated in the report (see p. 2), financial monitoring

was not within the scope of our work. It is important to note that the

scope of our work was based on agreements with our requesters and

was not influenced by whether or not financial monitoring information

is included in OJP’s annual financial statement audit.

4. According to the OJP Handbook: Policies and Procedures for the

Administration of OJP Grants (Feb. 1992), official grant files kept by

the Office of Comptroller Control Desk are to contain documents

relating to each grantee, including progress and financial reports and

site visit reports. In addition, for documentation to be readily available

for examination, as required by the Comptroller General’s internal

control standards, keeping them in the official grant files seems

appropriate.

5. As we reported, in our review of closeout procedures, we waited more

than the required 180 days before reviewing grant files to allow

sufficient time for BJA and VAWO to complete the grant closeout

process (see footnote 24, p. 18). However, the files we reviewed did

not contain the required closeout documents.

6. As we reported, BJA and VAWO officials told us that supervisors

discuss monitoring activities with staff through informal discussions or

meetings, which could include one-on-one meetings with staff. As we

stated, it is possible that grant managers are conducting grant

monitoring activities even if no documentation exists. However,

without documentation, neither OJP, BJA, VAWO, nor we are

positioned to tell with any certainty whether such monitoring occurred

(see pp. 20-21).

7. We have amended the report to add some of this information (see p. 7).

As discussed in comment 1, we report on the growth in the number

GAO Comments
Appendix III: Comments From the

Department of Justice

Page 50 GAO-02-25 Justice Discretionary Grants

and dollar amount of VAWO discretionary grants in appendix I (see pp.

34-35).

8. We disagree. Financial monitoring was not part of our review as

clearly stated in our introduction. Therefore, we do not believe that the

title of this section, as stated, implies that financial monitoring was

part of our review.

9. We agree that the grant files did not always contain documentation and

acknowledge that the lack of documentation does not necessarily

indicate whether monitoring did or did not occur. As we stated in

comment 6, without required progress reports and other

documentation, neither OJP, BJA, VAWO, nor we are positioned to tell

with any certainty whether such monitoring occurred.

10. We have amended the report to add most of this information (see p.

20). A discussion of the development of VAWO’s management

information system can be found on page 21 of the report.

11. As discussed in comment 6 and as we reported, it is possible that grant

managers are conducting grant monitoring activities even if no

documentation exists. However, without documentation, neither OJP,

BJA, VAWO, nor we are positioned to tell with any certainty whether

such monitoring occurred.

12. We disagree. As we reported, the Comptroller General’s internal

control standards require that all transactions and other significant

events be clearly documented and that the documentation be readily

available for examination. Appropriate documentation is an internal

control activity to help ensure that management’s directives are

carried out. Without such documentation, OJP, BJA, and VAWO have

no assurance that grants are meeting their goals and funds are being

used properly.

13. We have amended the report to incorporate the first of these two

changes (see p. 31). However, as illustrated in figures 3 and 4, the

annual number of Byrne awards and the dollar amount of those awards

have generally increased, although there were some yearly decreases

(see pp. 33-34).

14. We reported that, according to VAWO officials, VAWO grant managers

have sometimes been responsible for additional duties beyond grant

monitoring over the last few years (see p. 19).
Appendix IV: GAO Contacts and Staff

Acknowledgments

Page 51 GAO-02-25 Justice Discretionary Grants

Laurie E. Ekstrand, (202) 512-8777

John F. Mortin, (202) 512-8777

In addition to the above, Kristeen G. McLain, Samuel A. Caldrone, Dennise

R. Stickley, Keith R. Wandtke, Jerome T. Sandau, Michele C. Fejfar, and

Ann H. Finley made key contributions to this report.

Appendix IV: GAO Contacts and Staff

Acknowledgments

GAO Contacts

Staff

Acknowledgments

(182106)

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